ACCIS has submitted its contribution to the European Commission’s stakeholder consultation on the draft Guidelines on the classification of high-risk AI systems under Article 6 of the AI Act, which closed on 23 July 2026.
In its response, ACCIS calls on the Commission to clarify that logistic regression and similar traditional statistical techniques do not constitute AI systems under Article 3(1) when used on a stand-alone basis — consistent with the Commission’s own Guidelines on the definition of an AI system and the opinions of the ECB and EIOPA, including EIOPA’s letter of 10 July.
ACCIS also recommends that the final Guidelines: provide practical examples of tools benefiting from the Article 6(3) exemption, such as transaction categorisation systems that do not assess creditworthiness; confirm that exempt systems remain outside high-risk scope even where their outputs feed into other systems; assess fraud detection tools by reference to the provider’s intended purpose; avoid extending prudential concepts of “material change” beyond the financial sector; and align the grandfathering provisions with the revised application timeline introduced by the AI Omnibus.
ACCIS looks forward to continued engagement with the AI Office.